- Your privacy is important to us. We strive to ensure that our use of your personal information is lawful, reasonable, and relevant to our business activities, with the ultimate goal of improving our services and your experience.
- Our site is not targeted at children under the age of 18. If you do not have capacity to contract, you may make purchases or access this site only under the supervision of your guardian.
Application of this policy
- us, namely Assistability Consultants CC trading as Steely, and our successors-in-title or assigns;
- you, namely a person who accesses our site, regardless of the device which you use to access it (e.g. a computer, mobile phone, tablet etc).
What is personal information?
- Personal information refers to private information about an identifiable person, such as your name and surname, gender, age, date of birth, contact details (e.g. your home address, postal address, e-mail address or phone number), physical location, ID number and your image (such as a private photograph on a social networking site).
- Other information which might be “personal” information may include –
- “device and device event information“: We may collect information such as your IP address, unique device identifier , the nature of the device which you used to access our site (e.g. a computer, tablet or smart phone, and which type thereof), the geographic location from which you accessed our site (i.e. the geographic location of your device), hardware model and settings, operating system type and version, browser type and version, browser language, system activity, crashes;
- “log information”: When you use our site, we may automatically collect and store certain information in server logs (i.e. our web servers automatically record and maintain a log of their activities when users access our site), which may include your “site activity information”, such as details of how, when and for how long you accessed and used our site and other site traffic and use information (e.g. the date and time of your site requests, referral web pages (i.e. which site pages directed you to our site), landing pages (i.e. the page at which you accessed our site), URLs, which pages you accessed, the number of pages viewed and the order of those pages, the amount of time spent on those pages, the number of clicks, and exit pages (i.e. sites which you navigated to when leaving our site);
- “location information”: We may use various technologies to determine your actual location, such as geographical data from your device (which is usually based on the GPS or IP location); and
- “unique application numbers”: Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to us when you install or uninstall such a service or when that service periodically contacts our servers, such as for automatic updates.
How we collect your personal information
- We may collect your personal information in three ways, namely –
- actively from you;
- passively from your device when you use our site; and
- passively from social networking sites (subject to your privacy settings).
Active collection of personal information from you
- Some areas of our site may require you to submit certain information in order for you to register for certain services or benefit from specified features, such as when you register on the site, request to receive any newsletters or make purchases, or participate in a particular activity, such as a promotional competition or other promotion (collectively referred to as the “value added services”). If you contact us, we may keep a record of that correspondence.
- Our site may also collect personal information from you by asking you specific questions and by permitting you to communicate directly with us, for example via e-mail, feedback forms, site comments and forums.
- In these situations, we will –
- ask you for particular information;
- inform you at each information point what information is required and what information is optional; and
- indicate the consequences if you don’t give us the relevant information. (You will generally need to provide us with the relevant information in order to take full advantage of the site features, particularly the value added services.)
- The information we may actively collect from you may include your –
- identifying information (e.g. your name, surname, username, unique identifier (if you haven’t chosen a username), gender, date of birth, profile picture and physical location);
- contact details (e.g. e-mail address, physical address, postal address, delivery address (to the extent that it is different to your physical or postal address) and phone number);
- banking details or other details necessary for us (or a third party) to process the payment for any purchases you make; and
- other information which we may request from you from time to time.
Passive collection of personal information from your device
- We passively collect some of your personal information from the device which you use to access and navigate through our site, using various technological means.
- One of the key ways in which we collect information passively is using server logs to collect and maintain log information (see paragraph 2 above).
- A cookie is a small piece of data (an alphanumeric identifier) which our computer system transfers to your device through your web browser when you visit our site and which is stored in your web browser. When you visit the site again, the cookie allows the site to recognise your browser. Cookies may store user preferences and other information. For example, this allows you to retain items in your shopping cart and for us to recognise you when you next visit our site.
- Cookies also enable us to analyse usage of our site, diagnose problems with our server, aggregate and report information, ensure our records are complete, accurate and up to date, determine the fastest route for your computer to use in connecting with our site, and better administer and improve the site, recognise you when you next access our site to remember your preferences and to tailor our services to you, manage and target advertising on our site, as well as to compile aggregate information about your access to and use of our site. This information can be used to enhance the content of our site and make it more user-friendly, as well as to give you a more personalised experience.
- The information which we may passively collect from your device may include your identifying information, contact details, device and device event information, site activity information, log information, telephony log information, location information, unique application numbers (see paragraph 9 above) and any other information which you permit us, from time to time, to passively collect from your device.
Why we collect your personal information and how we use it
- We use the information we collect to provide, maintain, and improve our services, to develop new ones, and to protect us, our services and our users. We constantly strive to improve our users’ experience, and so we also use the information we collect in order to offer you information and content which is more appropriately tailored for you.
- We may collect and use your personal information to –
- establish and verify your identity;
- to create your user account and ensure that it doesn’t duplicate an existing user account on our site and allow use of our site, products and services;
- maintain and update our customer, or potential customer, databases;
- greet you when you access our site;
- communicate with you in various ways such as e-mail, post, telephonically, SMS notifications, instant messaging or other notifications to your device (e.g. on-screen pop-up messages);
- request feedback on our site, products and services, address any issues and liaise with users in that regard;
- keep a record of our communications with you and your communications with us;
- process your payment for your purchases;
- fulfil any contractual obligations we may have to you or any third party;
- provide you with value added services (see paragraph 11 above);
- improve the content of our site and our products and services;
- improve your user experience and the overall quality of our services;
- customise our site to your preferences and tailor information and/or content for you to ensure that it is presented in the most effective manner for you and for your device;
- inform you of facts relating to your access to and use of our site;
- inform you about our products and services which we think may interest you;
- inform you about competitions, promotions and special offers from us;
- carry out marketing, product research and development;
- to tailor general advertising on the site more appropriately for particular user groups;
- to compile and use statistical information about you and other users and their access to and use of our site, browsing habits, click-patterns, preferences, demographics etc. which we may use to develop, provide and improve the site and our products and services;
- to compile, use, disclose and trade with non-personal statistical information about our users and their access to and use of our site, browsing habits, click-patterns, preferences, demographics etc which we and/or our advertisers may use to develop, provide and improve the site and our products and services, including targeted advertising to user groups. Please note that the information referred to in this paragraph 21 is aggregate information about our users which has de-identified users’ personal information such that it cannot be linked back to identify you. We will not disclose your identifiable personal information to anyone without your permission;
- diagnose and deal with technical issues and customer support queries and other user queries, such as problems with our server, determine the optimal and fastest route for your device to use in connecting with our site, and administer, maintain and secure the site;
- comply with the law or with any legal process; and
- other activities not specifically mentioned which are lawful, reasonable, relevant to our business activities, and the minimum necessary and adequate in order for us to provide the site, and our products and services, including the value added services.
- We will get your permission before collecting or using your personal information for any other purpose.
Compulsory/optional information and consequences of not sharing it with us
- Only the following information is compulsory: Your e-mail address, username, contact details, banking details or other details required in order for us to process your purchase. In order to access any of the value added services you will need to identify yourself as a living person (not a bot).
- All other information is optional. If you do not agree to share your compulsory information with us, then you will not be able to make full use of the features that are offered to registered users. If you do not agree to share your optional information with us, then you may not be able to enjoy all of the site features and functionality.
Retention of your personal information
- We retain all personal information which we collect from you unless there is a valid technical, legal or business reason for us to delete, destroy or de‑identify it (“retained information”).
- We may keep all retained information for as long as you continue to access our site and for three years thereafter. Subject to paragraph 29 below, if you do not access our site for a consecutive period of three years we will delete, destroy or de‑identify all your personal information from our records except for information which we store for historical, statistical or research purposes.
- we are required by law, a code of conduct or a contract with you to keep it;
- we reasonably need it for lawful purposes related to our functions and activities;
- we reasonably need it for evidentiary purposes; or
- you agree to us keeping it for a specified further period.
- We store all retained information on our servers in South Africa. Please see paragraphs 42 to 44 below regarding our security measures.
Disclosure of your personal information
- We may disclose your personal information to –
- our employees, contractors, agents and third party service providers if and to the extent that they need to know that information in order to process it for us and/or to provide services for or to us, such as site hosting, development and administration, technical support, financial services such as processing of payments, delivery services, marketing services (only in respect of our site, products and services) and other support services. We will authorise any information processing done by a third party on our behalf, amongst other things by entering into written agreements with those third parties governing our relationship with them and containing confidentiality and non-disclosure provisions. Such persons may be disciplined, their contracts terminated or other appropriate action taken if they fail to meet their obligations;
- in order to protect our rights, property or safety or that of our customers, employees, contractors, agents and any other third party;
- in order to mitigate any actual or reasonably perceived risk to us, our customers, employees, contractors, agents or any other third party;
- any third party who acquires (or proposes to acquire) ownership or control of our assets, shares or management, or that of our affiliates, and/or our site, whether by sale, merger, acquisition or otherwise, and/or to any third party from who we acquire (or propose to acquire) ownership or control of assets, shares or management, whether by purchase, merger, acquisition or otherwise;
- governmental agencies, exchanges and other regulatory or self-regulatory bodies if we are required to do so by law or if we reasonably believe that such action is necessary to –
- comply with the law or with any legal process;
- protect and defend the rights, property or safety of us, our affiliates or our customers, employees, contractors and agents or any third party;
- protect the rights, property or safety of members of the public (if you provide false or deceptive information about yourself or misrepresent yourself as being someone else, we may proactively disclose such information to the appropriate regulatory bodies and/or commercial entities).
- We may use your personal information to compile profiles for statistical purposes and may freely trade with such profiles and statistical data, provided that the profiles or statistical data cannot be linked back to you by a third party.
- We will get your permission before disclosing your personal information to any third party for any other purpose.
Accuracy of your personal information
- We are careful to ensure that your personal information is accurate, complete, not misleading, and up to date. Please let us know if, to your knowledge, any information we have about you is incorrect, incomplete, misleading or out of date, by notifying us at the contact details set out in paragraph 49 below. We will take reasonable steps to correct or update the relevant information accordingly having regard to the purpose for which the information was collected or used. It is your responsibility to ensure that your personal information is correct, complete and up to date.
- If you contest the accuracy of your personal information, we may elect to verify its accuracy and, if we do so, we may restrict the processing of the contested information for a reasonable period while we verify its accuracy.
- You may refuse to accept, require us to discontinue, or pre-emptively block any approach or communications from us if that approach or communication is primarily for the purpose of direct marketing (“direct marketing communications”).
- You may opt out of receiving direct marketing communications from at any time by requesting us (in any manner, whether telephonically, electronically, in writing or in person) to desist from initiating any direct marketing to you.
- If you have opted out in accordance with clause 38, we will –
- send you written (which may include electronic writing) confirmation of receipt of your opt out request; and
- not send you any further direct marketing communications.
- You may (in terms of the Consumer Protection Act, 2008) register a pre‑emptive block against direct marketing communications. If you do so, we will not send you direct marketing communications unless you have expressly consented to receiving direct marketing communications from us.
- We will not send you direct marketing communications at home at any period during which it is prohibited by law to do so, unless you have expressly or implicitly requested or agreed otherwise.
- Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information in the course of its transmission. Once we have received your information, we will store some of it on our servers and use generally accepted procedures and security features to try to prevent unauthorised access to it.
- We take reasonable technical and organisational measures to secure the integrity of retained information, using accepted technological standards to –
- prevent unauthorised access to or disclosure of your personal information; and
- protect your personal information from misuse, loss, alteration or destruction.
- In particular:
- We require you to enter a password when logging in to our site to make a purchase.
- We do not require your Internet banking details or PIN numbers for any purpose. If we need to make a payment to you (e.g. a refund), we will send you an e-mail requesting your banking details and make payment directly into your chosen bank account. We may also elect to reverse the payment on your credit card or use another method we consider appropriate. We will not disclose your banking details to any third party except to the extent necessary to process and record payments, credits or refunds.
- From time to time we review our information collection, storage and processing practices, including physical security measures, to keep up to date with best practice.
- See paragraph 1 regarding measures to protect the information which is provided to employees, agents and contractors on a need-to-know basis.
Linking to third party sites
- We are not responsible for the privacy practices of a third party site to which there may be a link on our site or to which you may log in from our site (e.g. integrated social networking services).
Changes to this policy
What you can do to protect your personal information
- People have different privacy concerns. Our goal is to be clear about what information we collect so that you can make meaningful choices about what you make available. For example, you may –
- control who you share information with, on or via our site;
- set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being sent by us (see paragraphs 17 to 20 above);
- request us to indicate what personal information of yours we have on our systems;
- request us to correct or update your personal information (see paragraphs 35 and 36 above) or to destroy or delete your personal information (subject to paragraph 29 above);
- object to any unlawful processing of your personal information; and
- refuse the processing of your personal information for direct marketing purposes (see paragraph 37 to 40 above).
Queries and complaints
- If you contact us we may ask you to verify your identity before we can act on your request.
- Please note that we may reject requests that are vexatious or frivolous, unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or which would be disproportionately impractical to address.